Commonwealth v. Haith

Summary

The Massachusetts Supreme Judicial Court affirmed the defendant's first-degree murder conviction. It held that suppression of statements was not warranted based on the failure to advise the defendant of his Massachusetts telephone-call right while he was held in Federal custody in North Carolina, and it upheld admission of an autopsy photograph. The court also concluded that the evidence did not support an imperfect-defense-of-another manslaughter instruction and found no basis for relief under G. L. c. 278, § 33E.

Holdings

1. Even assuming that Massachusetts law required the troopers to advise the defendant of his statutory telephone right while he was held in Federal custody in North Carolina, suppression was unwarranted because the record did not show an intentional violation designed to coerce the defendant or gain an investigative advantage.
2. The trial judge did not abuse his discretion by admitting the autopsy photograph because it was relevant to the deliberate-premeditation and extreme-atrocity-or-cruelty theories of first-degree murder, and the defendant did not meet the heavy burden required to overturn the evidentiary ruling.
3. The evidence did not warrant an imperfect-defense-of-another instruction because, even viewed favorably to the defendant, his purposeful and brutal killing was not an excessive use of force in an otherwise reasonable or appropriate defense of another.
4. The court found no basis to reduce the first-degree murder conviction or order a new trial under § 33E.

Questions Presented

1. Whether the defendant's statements to Massachusetts State troopers in North Carolina should have been suppressed because he was not advised of his Massachusetts statutory right to use a telephone under G. L. c. 276, § 33A.
2. Whether the trial judge abused his discretion by admitting an autopsy photograph depicting the victim's skull and a bent screwdriver inserted into a puncture wound.
3. Whether the evidence warranted an instruction on imperfect defense of another that could have supported a manslaughter conviction.
4. Whether the conviction should be reduced or a new trial ordered under G. L. c. 278, § 33E.

Disposition

affirmed